Low reported severity Media Coverage

UK passport photo checker told Black applicants their closed mouths looked open, they say; a BBC test found darker-skinned women flagged more often

The UK government's online passport application uses an automated face-detection check that tells applicants when it thinks an uploaded photo breaks the rules, which include a neutral expression and a closed mouth. In September 2019 PA reported that a young Black man renewing his passport online said the checker mistook his lips for an open mouth, and that to submit the photo anyway he had to write in a comment box that his mouth was closed and he just had big lips. PA also reported that a Black educational technologist said the system told her that her eyes looked closed and that it could not find the outline of her head; she told the BBC she uploaded 10 photographs over a week and each was rated poor, and PA reported that the Passport Office tweeted that it was sorry the service had not worked as it should. In October 2020 a BBC investigation reported that a Black student said she was wrongly told her mouth looked open on each of five photos and got one accepted only by writing a note challenging the verdict. The BBC fed 1,130 passport-style photos of politicians into the checker and found that photos of dark-skinned women were graded poor quality 22% of the time against 14% for light-skinned women; it reported that documents released under a 2019 freedom of information request showed the Home Office knew of the problem but judged overall performance good enough to launch. The Home Office said applicants can override the check, that the checker is a customer aid, and that its systems are improving.

AI system: HM Passport Office photo checker
Occurred: Apr 2019
Reported: 19 September 2019
Event location: United Kingdom

What the AI did: Made a claim about the person
Reported harm: Psychological Distress

Whose AI use: An institution’s AI use
Setting: Public services

Evidence: AI involvement reported · Causal attribution supported · 2 sources; 8 claims: 1 corroborated, 7 reported. 3 open questions
People reported harmed: At least 3 people

AI system as recorded: Automated face-detection photo check on the UK government's online passport application, supplied to the Home Office by an external provider it declined to name

Reported harm

The applicants say the checker wrongly told them their mouths looked open or their eyes closed, so they had to retry with new photos or write explanations to override it. The man describes annoyance, the technologist frustration over a week of attempts, and the student says she should not have had to override a system that was not built for her. The technologist received her passport and the student got a photo approved; no refused passport is reported.

Outcome

Unknown

The Home Office told PA in 2019 that applicants may override the automated check in the vast majority of cases and that it would keep improving the process, and told the BBC in 2020 that over nine million people had used the service and its systems were improving. No later change to the checker is reported in the inspected sources.

What remains unknown

The date of each applicant's attempts: the technologist posted in April 2019 according to PA, the man applied before 19 September 2019, and the student before 8 October 2020.
The supplier and design of the face-detection check; the Home Office declined to name the provider.
Whether the Home Office later changed or replaced the checker.

What the evidence supports

AI involvement: reported. PA and the BBC describe the passport website's photo check as an automated face-detection system that tells applicants when it thinks a photo breaks the rules. Three applicants say its verdicts about their own faces were wrong: it said a man's closed mouth was open, said a woman's eyes were closed and could not find the outline of her head, and said a student's mouth looked open on five photos. Those wrong verdicts are what made them retry or write overrides. The Home Office did not deny the failures; the BBC test and the 2019 FOI documents report a wider skin-tone pattern but do not establish the cause in each applicant's case.

8 claims: 1 corroborated, 7 reported. What the statuses mean

Corroborated The UK government's online passport application runs an automated face-detection check that tells applicants when it thinks an uploaded photo does not meet the rules, which include a neutral expression and a closed mouth.

Causal attribution. Function of the system as described independently by PA and the BBC.

irishnews.com(opens in new tab) supports · English
The facial detection system informs people when it thinks the photo uploaded may not meet strict requirements, which include a plain expression and the mouth to be kept closed.
bbc.co.uk(opens in new tab) supports · English
The passport application website uses an automated check to detect poor quality photos which do not meet Home Office rules. These include having a neutral expression, a closed mouth and looking straight at the camera.

Reported A young Black man renewing his passport online says the automated checker mistook his lips for an open mouth, and that to submit the photo anyway he had to write in the comment box that his mouth was closed and he just had big lips.

Causal attribution. The applicant's account to PA; the checker's message is attributed to him.

irishnews.com(opens in new tab) supports · English
A young black man hoping to renew his passport online was stunned when the automated photo checker mistook his lips for an open mouth.; My mouth is closed, I just have big lips.

Reported A Black educational technologist says the checker told her that her eyes looked closed and that it could not find the outline of her head, and that over a week she uploaded 10 photographs, each rated poor quality, before proceeding with one and receiving her passport.

Causal attribution. Her own account, given to PA and to the BBC; two interviews with one witness are one origin.

irishnews.com(opens in new tab) supports · English
She became frustrated after the system told her it looked like her eyes are closed and that it could not find the outline of her head.; proceeded with one of the images and received her passport without any further problems.
bbc.co.uk(opens in new tab) supports · English
She told the BBC she had attempted to upload 10 different photographs over the course of a week, and each one had been rated as "poor" quality by the site.

Reported PA reported that when the technologist posted about the problem on Twitter, the Passport Office replied that it was sorry the photo upload service had not worked as it should.

Causal attribution. PA's report of the Passport Office's reply; the tweet itself was not inspected.

irishnews.com(opens in new tab) supports · English
When posting about the issue on Twitter at the time, the Passport Office tweeted back to her, saying it was sorry the photo upload service hadn’t “worked as it should

Reported A Black student says the checker wrongly told her that her mouth looked open on each of five photos she uploaded, and that she got one approved after challenging the verdict by writing a note to say her mouth was closed; she said such systems should work well for everyone.

Causal attribution. The student's account to the BBC.

bbc.co.uk(opens in new tab) supports · English
One black student said she was wrongly told her mouth looked open each time she uploaded five different photos to the government website.; which involved writing a note to say her mouth was indeed closed.; It should be the norm for these systems to work well for everyone, she added.

Reported The BBC fed 1,130 passport-style photos of politicians into the checker and reported that photos of dark-skinned women were graded poor quality 22% of the time against 14% for light-skinned women, and that photos of women with the darkest skin were four times more likely to be graded poor quality than those of women with the lightest skin.

Causal attribution. The BBC's own test, which it says the Alan Turing Institute reproduced; reported as the BBC's finding.

bbc.co.uk(opens in new tab) supports · English
Dark-skinned women are told their photos are poor quality 22% of the time, while the figure for light-skinned women is 14%; Photos of women with the darkest skin were four times more likely to be graded poor quality, than women with the lightest skin.

Reported The BBC reported that documents released under a 2019 freedom of information request showed the Home Office was aware of the problem but decided overall performance was good enough to launch the checker, which an external provider it declined to name supplied.

Causal attribution. The BBC's account of the FOI documents, which were not inspected.

bbc.co.uk(opens in new tab) supports · English
Documents released as part of a freedom of information request in 2019 had previously revealed the Home Office was aware of this problem, but decided "overall performance" was good enough to launch the online checker.; The automated checker was supplied to the government by an external provider which it declined to name.

Reported The Home Office told PA in 2019 that in the vast majority of cases applicants whose photo fails the automated check may override it and submit the photo, and told the BBC in 2020 that over nine million people had used the service and its systems were improving.

Causal attribution. The Home Office's statement, kept as its response.

irishnews.com(opens in new tab) supports · English
In the vast majority of cases where a photo does not pass our automated check, customers may override the outcome and submit the photo as part of their application.
bbc.co.uk(opens in new tab) supports · English
Over nine million people have used this service and our systems are improving.

Sources

2 sources inspected. Sources that repeat one account do not corroborate each other.

PA via The Irish News, passport photo checker falsely flags black man's lips as open mouth, 19 September 2019(opens in new tab)
s1 · irishnews.com · News report · English · Inspected · 19 September 2019 · Primary
BBC News, UK passport photo checker shows bias against dark-skinned women, 8 October 2020(opens in new tab)
s2 · bbc.co.uk · News report · English · Inspected

How the sources were read, and where the events happened

Read in English on 2026-10-29; no translation. Applies to s1, s2.

Event countries: United Kingdom. Affected-person countries: United Kingdom. Court countries: Unknown.

The check is part of the UK government's online passport application. PA and the BBC place the three applicants in England.

Reviewed for publication 2026-10-29: Published as a government service's automated face-detection check making wrong statements about three described applicants' faces: they say it called closed mouths open and eyes closed and made them retry or override it. Their accounts are attributed; the BBC's group-level test and the Home Office's response are recorded separately.

People described

Three Black applicants using the UK online passport service in 2019-2020 who described the checker's verdicts to PA or the BBC: a young man renewing his passport, an educational technologist and a student

People reported harmed in this case

At least 3 people

3 AI participants · 0 other people harmed

Three applicants each describe the checker misreading their own photos (PA: a man and a technologist; BBC: a student and the same technologist, counted once). PA says the man's case was not isolated, and the BBC test shows higher failure rates for darker-skinned people, but neither gives a count of other applicants harmed, so three is a minimum.

Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.

Cite this case

Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.

APA

NOPE. (2026). UK passport photo checker told Black applicants their closed mouths looked open, they say; a BBC test found darker-skinned women flagged more often. AI incidents. https://nope.net/incidents/2019-uk-passport-online-photo-checker-told-black-applicants-their-closed-mouths-looked-open

BibTeX

@misc{2019_uk_passport_online_photo_checker_told_black_applicants_their_closed_mouths_looked_open,
  title = {UK passport photo checker told Black applicants their closed mouths looked open, they say; a BBC test found darker-skinned women flagged more often},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2019-uk-passport-online-photo-checker-told-black-applicants-their-closed-mouths-looked-open}
}

London: Met Police live facial recognition wrongly matched a man to his watchlisted brother; officers stopped him and he later received a settlement

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Low Anima Annie

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Low Facewatch facial recognition

London shopper says staff told him Sainsbury's facial recognition flagged him as a shoplifter and he was escorted out; retailer blames human error

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Low AI Andi

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